Kathryn Cheshire v. Commissioner of Internal Revenue

KING, Chief Judge:

The Commissioner of Internal Revenue assessed a tax deficiency and associated penalties against Petitioner — Appellant Kathryn Cheshire. In the United States Tax Court, Cheshire asserted claims for innocent spouse relief from the tax deficiency and penalties under § 6015(b), (c), and ffi of the Internal Revenue Code. 26 U.S.C. § 6015 (Supp.2001). The Tax Court denied Cheshire’s request for innocent spouse relief, and Cheshire appeals that denial. For the following reasons, we AFFIRM the judgment of the Tax Court.

I. Factual History

The facts in this case are undisputed.…